Table of Contents
- Do Amazon Sellers Need to Comply with EPR?
- The EPR Thresholds for Amazon Sellers
- FBA Sellers: What Packaging Are You Responsible For?
- Self-Fulfilled Sellers: Your Packaging Obligations
- Multi-Channel Sellers
- Amazon’s Own EPR Compliance vs Yours
- How to Track Your Packaging Weight
- Practical Steps for Amazon Seller Compliance
- Worked Examples
- Common Questions from Amazon Sellers
Key Takeaways
- Amazon sellers are individually responsible for EPR compliance if they meet the thresholds (£1m+ turnover, 25+ tonnes packaging).
- FBA sellers are responsible for the product packaging they send to Amazon’s warehouses — Amazon is responsible for the shipping packaging it uses to fulfil orders.
- Self-fulfilled sellers are responsible for both product packaging and shipment packaging.
- Amazon does not handle EPR compliance on your behalf — you must register and report independently.
- Multi-channel sellers must aggregate packaging across all channels (Amazon, Shopify, eBay, wholesale) when assessing their obligations.
If you sell products on Amazon UK, the packaging EPR regulations apply to you just as they do to any other business placing packaged goods on the UK market. Many Amazon sellers assume that because they sell through a marketplace platform, Amazon handles compliance on their behalf. This is not the case. As the brand owner or importer of the products you sell, you have your own distinct EPR obligations.
This guide explains exactly how EPR applies to Amazon FBA sellers, self-fulfilled sellers, and multi-channel businesses, with practical guidance on tracking packaging weight and meeting your reporting requirements.
Do Amazon Sellers Need to Comply with EPR?
The same thresholds that apply to all UK businesses apply to Amazon sellers. You are an obligated producer under packaging EPR if:
- Your annual turnover is £1 million or more (across all sales channels, not just Amazon)
- AND you handle 25 or more tonnes of packaging per year
Both thresholds must be met. If your total business turnover across all channels exceeds £1 million and your total packaging tonnage exceeds 25 tonnes, you are obligated — regardless of whether you sell through Amazon, your own website, eBay, or physical retail.
If you are not sure whether your business meets these thresholds, our guide to packaging EPR explains them in detail, and our small vs large producer guide covers the classification system.
Turnover Calculation for Amazon Sellers
Your turnover for EPR purposes is your total annual revenue from all sources, not just Amazon sales. This includes:
- Amazon UK marketplace revenue (including VAT if applicable)
- Sales through your own website (Shopify, WooCommerce, etc.)
- Sales through other marketplaces (eBay, Etsy, TikTok Shop, etc.)
- Wholesale revenue
- Any other revenue streams
Many Amazon sellers who believe they are below the £1 million threshold are surprised when they aggregate revenue across all their channels.
Packaging Tonnage for Amazon Sellers
Similarly, your packaging tonnage includes all packaging across your entire business — not just the packaging associated with Amazon orders. This includes product packaging, transit packaging, and shipment packaging from every sales channel.
FBA Sellers: What Packaging Are You Responsible For?
Fulfilment by Amazon (FBA) creates a split in packaging responsibility between you and Amazon. Understanding this split is essential for accurate EPR reporting.
Your Responsibility (FBA Seller)
As an FBA seller, you are responsible for the packaging on the products you send to Amazon’s fulfilment centres. This includes:
Product packaging (Primary — P1):
- The packaging that directly contains your product (boxes, bottles, bags, blister packs)
- Inner packaging such as tissue paper, foam inserts, or product wrapping
- Labels on the product packaging
Multipack packaging (Secondary — P2):
- Packaging used to group multiple units together (e.g., shrink-wrapped bundles, cardboard sleeves around multipacks)
Transit packaging you send to Amazon (Tertiary — P3):
- The outer cartons or cases you use to ship your products to Amazon’s fulfilment centres
- Pallet wrap, strapping, corner protectors, and other transit materials you use
- Packaging labels and documentation sleeves
Amazon’s Responsibility
Amazon, as the entity that ships the product from its fulfilment centre to the end consumer, is responsible for:
Shipment packaging (SP):
- The Amazon-branded shipping box or mailer used to deliver the order to the customer
- Amazon’s void fill, bubble mailers, and paper padding
- Amazon’s shipping labels and packing slips
This means you do not need to report the weight of Amazon’s brown shipping boxes or mailer bags. Amazon has its own EPR obligations as a business that packs and ships goods, and it reports its own shipment packaging independently.
What About “Ships in Own Container” (SIOC)?
If your product is enrolled in Amazon’s Ships in Own Container programme — meaning Amazon ships the product in its original packaging without adding an Amazon box — the responsibility becomes more nuanced:
- The product packaging that Amazon ships directly is still your responsibility as the brand owner
- Since Amazon does not add its own shipment packaging, there is no Amazon shipment packaging to account for
- However, if Amazon adds a label or minimal packaging (a polybag, for example), that minimal addition may be Amazon’s responsibility
In practice, SIOC products simplify the split because your product packaging is the only packaging involved in the order.
Self-Fulfilled Sellers: Your Packaging Obligations
If you fulfil Amazon orders yourself (Merchant Fulfilled Network / MFN), you are responsible for all packaging associated with those orders:
Product packaging (P1):
- Same as FBA — all packaging directly containing the product
Multipack packaging (P2):
- Same as FBA — grouping or bundle packaging
Shipment packaging (SP):
- The shipping box, mailer bag, or padded envelope you use to send orders to customers
- Void fill, bubble wrap, tissue paper, packing peanuts
- Packing tape
- Shipping labels and documentation
Transit packaging (P3):
- Packaging used to receive goods from your suppliers (if you are the importer or first handler)
Self-fulfilled sellers therefore have a larger packaging footprint to report than FBA sellers, because they are also responsible for the shipment packaging that Amazon would otherwise handle.
Multi-Channel Sellers
Most Amazon sellers also sell through other channels — their own website, eBay, wholesale accounts, or physical retail. For EPR purposes, you must aggregate your packaging across all channels.
Example: Multi-Channel Electronics Seller
A seller of electronics accessories with the following channels:
| Channel | Annual Revenue | Packaging Type |
|---|---|---|
| Amazon FBA | £600,000 | Product + transit to Amazon |
| Own Shopify store | £350,000 | Product + shipment to customers |
| eBay (self-fulfilled) | £150,000 | Product + shipment to customers |
| Wholesale to retailers | £200,000 | Product + transit cases |
| Total | £1,300,000 |
This business exceeds the £1 million turnover threshold. It now needs to assess whether its total packaging tonnage across all four channels exceeds 25 tonnes. The packaging includes:
- Product packaging across all channels (same products, same packaging)
- Shipment packaging for Shopify and eBay orders (mailer bags, shipping boxes)
- Transit packaging sent to Amazon’s FBA warehouses
- Transit packaging used for wholesale deliveries to retailers
Many multi-channel sellers discover they are obligated only when they aggregate packaging across all channels.
Amazon’s Own EPR Compliance vs Yours
It is important to understand the boundary between Amazon’s EPR obligations and yours. Amazon is itself an obligated producer under EPR, but its obligations relate to:
- Amazon’s own packaging — The boxes, mailers, void fill, and tape Amazon uses to ship FBA orders
- Amazon’s marketplace operator obligations — As an online marketplace, Amazon has specific obligations under EPR regulations regarding third-party sellers
What Amazon Does NOT Do For You
Amazon does not:
- Register you on the RPD portal
- Report your product packaging data on your behalf
- Pay your EPR fees
- Track or calculate your packaging weight
- Provide you with packaging weight data for your products
- Exempt you from EPR obligations because you sell on its platform
Your EPR compliance is entirely your own responsibility. Amazon may provide some data (such as the number of units sold or shipped) that helps you calculate packaging quantities, but the obligation to register, report, and pay fees rests with you.
Amazon’s Marketplace Operator Obligations
Under the reformed EPR regulations, online marketplace operators have specific obligations. Amazon, as a marketplace, may need to report certain data about packaging sold through its platform. However, this does not replace the individual seller’s obligation to register and report if they meet the thresholds. The marketplace operator provisions are designed to capture packaging from overseas sellers who may not otherwise register in the UK — they do not absolve UK-based sellers of their own obligations.
How to Track Your Packaging Weight
Accurate packaging weight data is essential for EPR reporting. Here are practical approaches for Amazon sellers:
Method 1: Supplier Specification Sheets
Request packaging specifications from your suppliers for every packaging component — product boxes, polybags, labels, inserts, shrink wrap. These specifications typically include component weights and material types. This is the most accurate method and creates a reliable audit trail.
Method 2: Weigh a Sample
If supplier specs are not available, weigh a sample of each packaging item using a digital scale accurate to at least 1 gram. Weigh multiple samples (5-10) and use the average. Record the weights in a spreadsheet alongside the material type and packaging category.
Method 3: Calculate from Order Volume
Once you know the weight per unit of each packaging type, multiply by the number of units used. Amazon Seller Central provides order volume data that can be used to calculate:
- Number of units sold (to calculate product packaging)
- Number of shipments sent to FBA (to calculate transit packaging to Amazon)
- Number of customer orders fulfilled (for self-fulfilled sellers, to calculate shipment packaging)
What to Weigh
Do not forget these commonly overlooked packaging items:
- Polybags around individual products (even thin ones have weight)
- Labels — product labels, shipping labels, barcode labels
- Packing tape on boxes you send to Amazon
- Desiccant packets in packaging (counted as “Other” material)
- Warranty cards and instruction booklets in product boxes (paper/card)
- Foam inserts and cushioning inside product packaging (plastic or paper)
- Rubber bands and ties used to secure products in packaging
- Shrink wrap around multipacks or pallets
For a comprehensive guide to measurement methods, see our packaging weighing guide.
Practical Steps for Amazon Seller Compliance
Step 1: Assess Your Thresholds
Calculate your total annual turnover across all sales channels. If it exceeds £1 million, move to the tonnage assessment. List every type of packaging your business handles and estimate the annual weight. If it exceeds 25 tonnes, you are obligated.
Step 2: Determine Your Producer Category
Using our small vs large producer guide, determine whether you are a small or large producer. This determines your reporting frequency (annual or half-yearly).
Step 3: Register on the RPD Portal
Register your business on DEFRA’s Report Packaging Data portal via GOV.UK. You will need your Company Registration Number, registered address, and details of your obligated activities.
Step 4: Set Up Packaging Tracking
Create a system to record packaging data. At minimum, you need to track:
- Each packaging item (product box, polybag, mailer, etc.)
- Material type (plastic, paper/card, glass, etc.)
- Weight per unit
- Annual quantity
- Packaging category (primary, secondary, tertiary, shipment)
Step 5: Collect Data Through the Year
Record packaging data monthly or quarterly — do not leave it until the submission deadline. For FBA sellers, Amazon’s inventory and shipment reports can help you track unit volumes, which you can then multiply by per-unit packaging weights.
Step 6: Submit and Pay
Submit your data by the relevant deadline (1 October for H1, 1 April for H2/annual). After submission, PackUK will calculate your fees and send an invoice.
Worked Examples
Example 1: Small FBA Seller (Below Threshold)
Business: Private-label kitchen accessories sold exclusively on Amazon FBA Annual turnover: £400,000 Packaging: Product boxes (card), polybags, bubble wrap
Assessment: Turnover is below £1 million. Not obligated, regardless of packaging tonnage. No action required, but should reassess annually as the business grows.
Example 2: Mid-Size FBA Seller (Small Producer)
Business: Private-label beauty products, multi-channel Annual turnover: £1.5 million (£900k Amazon, £400k Shopify, £200k wholesale) Packaging handled:
| Item | Material | Weight/Unit | Annual Units | Annual Weight |
|---|---|---|---|---|
| Product boxes (card) | Paper and card | 80g | 200,000 | 16,000 kg |
| Plastic bottles (product) | Plastic | 25g | 200,000 | 5,000 kg |
| Polybags | Plastic | 5g | 200,000 | 1,000 kg |
| Outer cartons (to Amazon) | Paper and card | 400g | 8,000 | 3,200 kg |
| Shipping boxes (Shopify) | Paper and card | 300g | 15,000 | 4,500 kg |
| Mailer bags (Shopify) | Plastic | 30g | 10,000 | 300 kg |
| Total | 30,000 kg (30 tonnes) |
Classification: Small producer (turnover £1-2m, tonnage 25-50 tonnes). Reports annually by 1 April.
Estimated annual EPR fees:
- Paper and card: 23.7 tonnes x £196 = £4,645
- Plastic: 6.3 tonnes x £423 = £2,665
- Total: £7,310
Example 3: Large FBA + Self-Fulfilled Seller (Large Producer)
Business: Consumer electronics, high volume across Amazon FBA, own website, and eBay Annual turnover: £4 million Packaging handled:
| Item | Material | Annual Weight |
|---|---|---|
| Product boxes (card) | Paper and card | 25 tonnes |
| Plastic inserts/trays | Plastic | 8 tonnes |
| Polybags | Plastic | 2 tonnes |
| Outer cartons to Amazon FBA | Paper and card | 10 tonnes |
| Shipping boxes (own site + eBay) | Paper and card | 12 tonnes |
| Void fill (own site + eBay) | Paper and card | 2 tonnes |
| Packing tape | Plastic | 0.5 tonnes |
| Shrink wrap | Plastic | 1.5 tonnes |
| Total | 61 tonnes |
Classification: Large producer (turnover above £2m, tonnage above 50 tonnes). Reports every 6 months.
Estimated annual EPR fees:
- Paper and card: 49 tonnes x £196 = £9,604
- Plastic: 12 tonnes x £423 = £5,076
- Total: £14,680
Common Questions from Amazon Sellers
”Does Amazon report my packaging for me?”
No. Amazon reports its own packaging (the shipping boxes and materials it uses for FBA fulfilment). You must report your product packaging and any transit packaging you send to Amazon’s warehouses independently.
”I sell on Amazon but my products come pre-packaged from China. Am I an importer?”
Yes. If you import packaged goods into the UK for sale on Amazon, you are performing an obligated activity (importing) and are responsible for all packaging on those imported goods — product packaging, inner packaging, and any transit packaging that enters the UK. See our EPR guide for importers for detailed information.
”What if I use Amazon’s packaging materials (e.g., ASIN labels)?”
Packaging materials that Amazon provides and applies (such as FNSKU labels or Amazon-specific packaging requirements) are generally Amazon’s responsibility as the entity that applies them. However, any packaging you apply before sending products to Amazon is your responsibility.
”Do I need to count packaging on products I buy from UK wholesalers and resell?”
If you buy products from a UK wholesaler and resell them without repackaging, the packaging may already be accounted for by the original brand owner or packer. However, any additional packaging you add (such as multipack shrink wrap or shipping boxes) is your responsibility. The rules on activity precedence in the RPD guidance determine who is responsible in supply chain scenarios.
”I am below £1 million turnover now but growing fast. When should I start preparing?”
We recommend starting to track packaging data as soon as your turnover exceeds £750,000, so that if you cross the £1 million threshold, you already have the systems and data in place to comply. The administrative effort of retrospectively reconstructing a year of packaging data is significantly greater than tracking it as you go.
”What about the Plastic Packaging Tax? Do I need to comply with both?”
The Plastic Packaging Tax (PPT) and packaging EPR are separate regulations with different thresholds and requirements. You may need to comply with both if you meet the thresholds for each. PPT applies to businesses that manufacture or import 10 or more tonnes of plastic packaging per year, with a tax of £217.85 per tonne on packaging containing less than 30% recycled content.
Get Started with EPR Compliance
Navigating EPR as an Amazon seller does not need to be complicated. Our platform is designed for e-commerce businesses and makes it simple to track packaging across multiple sales channels, calculate your obligations, and generate DEFRA-ready reports.
For broader guidance on online selling and EPR, read our packaging EPR for online sellers guide. If you also sell subscription boxes, see our subscription box EPR guide. And for a step-by-step walkthrough, use our EPR compliance checklist.
Start your free trial and see how easy EPR compliance can be for your Amazon business.